P.O. Box 843, Needham, MA 02494 Telephone: 781-449-2214 Fax: 781-449-6464 Email: rad_sci_health@comcast.net rad_sci_health@comcast.net

June 27, 2000

Senator Pete V. Domenici
328 Hart Senate Office Building
Washington, D.C. 20510-3101

Subject: Challenging the False Linear No-Threshold (LNT) Presumption

Dear Senator Domenici,

RSH, a group of international radiation science and policy experts, supports your questioning of the LNT. Our formal comments on EPA’s "radionuclides in water" rule, enclosed, state that:

• The LNT has no valid scientific basis. The National Council on Radiation Protection and Measurements (NCRP) itself, in NCRP-121 (1995) presents "LNT science" as:

"Few experimental studies, and essentially no human data, can be said to prove or even to provide direct support for the concept … It is conceptually possible, but with a vanishingly small probability, that any of these effects could result from the passage of a single charged particle, causing damage to DNA that could be expressed as a mutation or small deletion. It is a result of this type of reasoning that a linear non-threshold dose-response relationship cannot be excluded. (emphasis added)"

EPA’s LNT-based policies do a disservice to science. It acknowledged this in response to its own Scientific Advisory Board (SAB) on radium limits (56 Fed. Reg. 33,050-127), stating:

"The SAB/RAC urged EPA to base its risk assessment for radium on human epidemiology data on radium watch dial painters, rather than on modeled estimates,… and that if EPA continued to use the modeling approach, uncertainties in the modeling be addressed."

EPA elected to use LNT in the face of such contradictory scientific data, by stating:

"…use of the dial painter data requires either deriving a linear risk coefficient from significantly non-linear exposure-response data, or abandoning EPA policy…"

EPA’s calculated health risks, and the limits, are rationalized by this faulty LNT premise. This includes NCRP and BEIR support to EPA, which does not consider the "best available" scientific data on low-dose radiation health effects. Under this rubric, there is no limit to actions to reduce radiation despite the lack of possible public health benefits, at very high public cost.

Independent Individuals Knowledgeable in Radiation Science and Public Policy

Committed to Change Radiation Science policy in the Public Interest

Certainly, radiation at high doses and dose rates can damage health. But this EPA rule is for low-dose, low-dose-rate, exposures. Our views are shared by many others, e.g.:

Philip Abelson, Editor Emeritus of Science, in an editorial on "Risk Assessments of Low-Level Exposures," wrote:

"The current mode of extrapolating high-dose to low-dose effects is erroneous for … radiation. Safe levels of exposure exist. The public has been needlessly frightened and deceived, and hundreds of billions of dollars wasted. A hardheaded, rapid examination of phenomena occurring at low exposures should have a high priority." Science 265 (Sept. 9, 1996).

These extreme premises succeed in producing baseless public fear, provide no possible public health or safety benefit, prevent applying low-dose radiation for biological and health benefits, and unnecessarily constrain the cost-effective application of radiation technologies.

We present a partial selection of the extensive science sources that show that there are NO adverse health effects, and there are beneficial health effects:

1. Worker exposures (Nuclear plants, radium dial painters, medical workers);
2. Radiation exposure of medical patients;
3. High background area populations (10 to 100 times low background areas);
4. Medical use of low-dose radiation (stimulate health, treat cancer and other diseases);
5. Japanese A-bomb survivors;
6. Cellular and molecular biology, animal experiments, and cancer research;
7. Detrimental effects from reducing background radiation below natural levels;
8. Beneficial effects from supplements of low-dose radiation (and chemicals), sometimes called "hormesis," as with essential vitamins and minerals that are toxic and carcinogenic at high doses, and that these results have not been considered; and
9. Scientific data and conclusions are misrepresented and/or falsified to "support the LNT," in the scientific literature, and by the science and radiation protection agencies and their review body reports.

EPA is under court agreement to issue this rule in November, so they can not just delay. Court review will be undertaken if EPA continues to ignore the valid scientific data, and relies on misrepresented data, including that in NCRP and BEIR Committee reports.

We are hopeful that the GAO Report that you requested will confirm the many failures of the Federal agencies to consider the relevant data. This will support court and public policy actions.

Separately, please support the House initiative to stop EPA’s "radon in water" rule. This is similarly invalid, from "radon health effects" data, and as insignificant vs. background exposure.

Thank you very much.

Regards,

James Muckerheide                                                 Theodore Rockwell
President                                                                 Vice President

Enclosures